UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
April 15, 2011
GARY V. REYNOLDS,
ALLSTATE INSURANCE COMPANY, JANICE L. COSTANZO, AND DOES ONE
THROUGH TWENTY, INCLUSIVE,
The opinion of the court was delivered by: The Hon. Susan Illston
STEPHEN F. VON TILL (State Bar No. 47217) ONDREJ LIKAR (State Bar No. 260199) VON TILL & ASSOCIATES 152 Anza Street, Suite 220 Fremont, California 94539 Telephone: (510) 490-1100 Facsimile: (510) 490-1102 Attorney for Plaintiff GARY REYNOLDS MICHAEL BARNES (State Bar No. 121314) SONIA MARTIN (State Bar No. 191148) CYNTHIA LIU (State Bar No. 263270) SNR DENTON US LLP 2121 N. California Blvd., Suite 800 Walnut Creek, California 94596 Telephone: (925) 949-2600 Facsimile: (925) 949-2610 Email: firstname.lastname@example.org email@example.com firstname.lastname@example.org Attorneys for Defendant ALLSTATE INSURANCE COMPANY
STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN PRETRIAL DEADLINES
The parties, by and through their respective counsel of record, hereby stipulate and agree as follows and respectfully request that the Court approve and give effect to their stipulation:
WHEREAS the Court has set the following discovery deadlines: Non-expert discovery cut-off: May 12, 2011 Dispositive motion filing: July 8, 2011 (pltf); July 22, 2011 (deft) Dispositive motion hearing: September 2, 2011 Expert disclosures: May 19, 2011 Rebuttal expert disclosures: May 26, 2011 Expert discovery cut-off: June 10, 2011
WHEREAS, plaintiff's counsel has two trials scheduled in May 2011;
WHEREAS, plaintiff and non-party Janice L. Costanzo currently reside in Colorado;
WHEREAS, due to the schedules of the parties, they have been unable to find a mutually agreeable date for plaintiff's and non-party Janice L. Costanzo's depositions prior to May 12, 2011; 15
WHEREAS, a continuance of certain discovery deadlines will not affect
any other case
management dates set by the Court, including the trial date;
IT IS HEREBY STIPULATED AND AGREED that the pretrial deadlines should be modified as follows: Non-expert discovery cut-off June 30, 2011
Expert discovery cut-off: June 30, 2011
IT IS SO STIPULATED. FILER'S ATTESTATION: 4
Pursuant to General Order No. 45, section X(B) regarding signatures, I
penalty of perjury that the concurrence in the filing of this
document has been obtained from its 6 signatories.
IT IS SO ORDERED.
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